HomeMy WebLinkAbout4331 Resolution - WA ST AGs Distributors Settlement Agreement - Pharmacy RESOLUTION NO.4331
A RESOLUTION OF THE CITY OF PASCO, WASHINGTON,
AUTHORIZING THE INTERIM CITY MANAGER TO SIGN SETTLEMENT
PARTICIPATION FORMS FOR THE WASHINGTON OPIOID
SETTLEMENTS WITH(1)WALGREENS,(2)CVS,(3)WALMART,(4)TEVA,
AND (5) ALLERGAN ALONG WITH ANY OTHER DOCUMENTS
REQUIRED TO COMPLETE PARTICIPATION IN THE SETTLEMENT; AND
FURTHER AUTHORIZES THE INTERIM CITY MANAGER TO EXECUTE
THE ALLOCATION AGREEMENT AND PARTICIPATION FORMS.
WHEREAS,the people of the State of Washington and its communities have been harmed
by entities within the Pharmaceutical Supply Chain who manufacture, distribute, and dispense
prescription opioids; and
WHEREAS, certain Local Governments, through their elected representatives and
counsel, are engaged in litigation seeking to hold these entities within the Pharmaceutical Supply
Chain of prescription opioids accountable for the damage they have caused to the Local
Governments; and
WHEREAS, Local Governments and elected officials share a common desire to abate and
alleviate the impacts of harms caused by these entities within the Pharmaceutical Supply Chain
throughout the State of Washington, and strive to ensure that principles of equity and equitable
service delivery are factors considered in the allocation and use of Opioid Funds; and
WHEREAS, certain Local Governments engaged in litigation and other cities, such as the
City of Pasco and counties in Washington,wish to become"Participating Local Governments"by
agreeing on a form of allocation for Opioid Funds they receive from entities within the
Pharmaceutical Supply Chain; and
WHEREAS, the City Council of the City of Pasco is vested with the authority to sue and
be sued in courts and all proceedings and is also vested with authority to contract pursuant to RCW
35A.11; and
WHEREAS, the City of Pasco entered into the One MOU on May 27, 2022, as a
Participating Local Government bound by the distribution allocation as described in Exhibit A of
the One MOU; and
WHEREAS, the Washington State Attorney General is involved in litigation with (1)
Walgreens, (2) CVS, (3) Walmart, (4) Teva, and (5) Allergan ("Settling Distributors"); and
WHEREAS, the Attorney General's Distributors Washington Settlement Agreement has
added additional funds to the Global Settlement including the previously negotiated One MOU
with Keller Rohrback; and
Resolution—Washington Opioid Settlements with
(1)Walgreens, (2) CVS, (3)Walmart,(4) Teva, and(5)Allergan- 1
WHEREAS, the total Washington Abatement Amount is $434,000,000; and
WHEREAS, by entering into the Attorney General's negotiated Distributors Washington
Settlement Agreement, the Local Governments and State Government agree to split 50/50 the
Washington Abatement Amount with the Local Governments share being distributed in
accordance with the Allocation Agreement previously negotiated with Keller Rohrback in the One
MOU; and
WHEREAS, by entering into this Agreement, the Settling Distributors admit no fault or
wrong-doing and the Local Governments agree to dismiss with prejudice the current litigation
against them.
NOW,THEREFORE,BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY
OF PASCO, WASffiNGTON:
That the City Council of the City of Pasco approves the terms and conditions of the
Washington Opioid Settlements with (1) Walgreens, (2) CVS, (3) Walmart, (4) Teva, and (5)
Allergan Agreement between Washington State, the Participating Local Jurisdictions and the
Settling Distributors; a copy of which is attached hereto and incorporated herein by reference as
Exhibit B; and
Be It Further Resolved that in order to fully execute this Agreement, the City Council of
the City of Pasco further resolves to authorize the Interim City Manager to sign all necessary
documents for that purpose including the Participation Forms, copies of which are attached hereto
and incorporated herein by reference as Exhibit C, and
Be It Further Resolved,that this Resolution shall take effect immediately.
ouncil of the City of Pasco,Washington this 3rd day of April, 2023.
Blanche Barajas
Mayor
ATTEST: APPROVED AS TO FORM:
.
�..—-��
Debra Barham, CMC Kerr Ferg aw, PLLC
City Clerk City rneys
Resolution—Washington Opioid Settlements with
(1)Walgreens, (2) CVS, (3)Walmart, (4)Teva, and(5)Allergan-2
DocuSign Envelope ID:4481C543-1161-465A-B229-A1A1965A96C1
New National Opioids Settlements: Teva, Allergan, CVS, Walgreens, and Walmart
Opioids Implementation Administrator
opi _� ,c> ���rubrrs.�� �
Ellensburg city, WA
Reference Number: CL-393436
TO LOCAL POL/T/CAL SUBD/V/SIONS AND SPEC/AL D/STR/CTS:
YOU MUST TAKE ACTION IN ORDER TO PARTICIPATE IN FIVE NEW OPIOID
5 ETTLE M E NTS
Dead/ine:April I8, 2023
Five new proposed national opioid settlements ("Settlements") have been reached
with Teva, Allergan, CVS, Walgreens, and Walmart ("Settling Defendants"). These
new Settlements are in addition to the prior settlement with the opioid distributors,
and you will need to sign new settlement documents to join.
The Washington Attorney General's Office strongly encourages you to join these
new Settlements. As with the opioid distributor settlement, half of the Washington
share of the settlement proceeds will be directed to Washington local governments
for you to make decisions on how to remediate the opioid crisis in your
communities.
The Settlements are contingent on a very high percentage of Washington cities and
counties joining the Settlements. If you do not join, the Settlements may not be
finalized. Even if enough cities and counties join so that the Settlements are
finalized, your refusal to join would still substantially lessen the amount Washington
receives. The deadline for joining the Settlements by signing the required
documents is Tuesday, April 18, 2023.
How to join the settlements
In the electronic envelope attached to this email, you will find the documents that
your local government needs to execute. Please sign these documents and return
them to the Implementation Manager:
• Participation Forms for the (1) Teva, (2) Allergan, (3) CVS, (4) Walgreens, and
(5) Walmart settlements, which include a release of any claims. To join the
Settlements, you need to sign and submit each of these Participation Forms.
� Allocation Agreement ll. This is an agreement between the State and
Washington local governments to split the settlement proceeds for these five
Settlements, with 50% going to the State and 50% going to the local
governments. The local government share then will be split based on the One
Washington Memorandum of Understanding, which is attached to the
Allocation Agreement II.
DocuSign Envelope ID:4481C543-1161-465A-B229-A1A19B5A96C1
You can return the executed Participation Forms and Allocation Agreement ll to the
Implementation Administrator in one of the following ways: .
(1) Electronic Signature via DocuSign: Exe�uting the Participation Forms and
Allocation Agreement lI electronically through DocuSign will return the signed
forms to the Implementation Administrator and associate your forms with
your subdivision's records. Electronic signature is the most efficient method
for returning the documents and is strongly encouraged.
(2) Manual Signature returned via DocuSign: DocuSign allows forms to be
downloaded, signed manually, then uploaded to DocuSign and returned
automatically to the Implementation Administrator. Please be sure to
complete all fields.
(3) Manual Signature returned via electronic mail: If your subdivision is unable to
use DocuSign, the signed Participation Forms and Allocation Agreement ll
may be returned via electronic mail to c7�_ }ss�� _ r;; _ .�_
Please include the name, state, and reference ID of your subdivision in the
body of the email and use the subject �ine Settlement Participation Forms -
[Subdivision Name, Subdivision State] - [Reference ID].
Detailed instructions on how to sign and return the Participation Forms, including
changing the authorized signer, can be found at
https:llnationalapioidsettlement.com. You may also contact
o��ioids��artic�ation��rubris.cam_
The Participation Form for each settlement must be executed, without alteration,
and submitted on or before April 18, 2023, in order for your subdivision to be
considered for initial participation calculations and payment eligibility.
How to learn mor� al�out these settlements
This AGO press release has information on the five new Settlements and estimates
of Washington's settlement share if the settlements are finalized, all eligible
Washington local governments join, and all conditions are met:
https:ll��v -�.wa._oc� vine_��slnews-r� _ ._ �; � c;.,� _ _�awsuits-against-
three-nati�.,�.._=pharmacy-c ��_s-the . . o e.
Additionally, the AGO is coordinating with WSAC and AWC to host informational
meetings about the settlements in February 2023, and more information on those
meetings will follow.
You also may wish to consult with your own legal counsel.
If you have questions about this communication or the settlements, please contact
Jeff Rupert, the Division Chief for the AGO's Complex Litigation Division, at 206-389-
2116 or leffrey.RupertC��` . The AGO will be monitoring the sign-on
progress and encouraging all eligible local governments in Washington to join.
DocuSign EnvelopelD:4481C543-7161-465A-6229-A1A19B5A96C1
Information and documents regarding the New National Opioid Settlements can be
found on the national settlement website at https://nationalopiaidsettlement.com/.
What are the next steps after the April 18, 2023 deadline?
Based upon subdivision participation forms received on or before April 18th, the
subdivision participation rate will be used to determine whether participation for
each deal is sufFicient for the settlement to move forward and whether a state earns
its maximum potential payment under the settlement. If the settlement moves
forward, your release will become effective. If a settlement does not move forward,
that release will not become effective.
Any subdivision that does not participate cannot directly share in the settlement
funds, even if the subdivision's state is settling and other participating subdivisions
are sharing in settlement funds. Any subdivision that does not participate may also
reduce the amount of money for programs to remediate the opioid crisis in its state.
Please note, a subdivision will not necessarily directly receive settlement funds by
participating; decisions on how settlement funds will be allocated within a state are
subject to intrastate agreements or state statutes.
If the Settlements are finalized, the payment terms and payment schedule for the
settlement proceeds is specified in each Settlement.
The sign-on period for subdivisions ends on April 18, 2023.
Thank you,
National Opioids Settlements Implementation Administrator
The Implementation Administrator is retained to provide the settlement notice
required by the respective settlement agreements referenced above and t�'manage
the collection of settlement participation forms for each settlement.
EI�IIBIT K
Subdivision and Special District 5ettlement Particination Form
Governmental Entity: State:
Authorized Si atory:
Address 1:
Address 2:
City, 5tate,Zip:
Phone:
Email:
The governmental entity identified above ("Governmental Entity"), in order to obtain and in
consideration for the benefits provided to the Governmental Entity pursuant to the Agreement dated
November 22, 2022 ("Allergan Senlement"), and acting through the undersigned authorized official,
hereby elects to participate in the Allergan Settlement,release all Released Claims against all Released
Entiries, and agrees as follows.
1. The Governmental Entity is aware of and has reviewed the Allergan Settlement, understands
that all terms in this Election and Release have the meanings defined therein, and agrees that
by this Election, the Governmental Entity elects to participate in the Allergan Settlement as
provided therein.
2. Following the execution of this Settlement Participation Form, the Governmental Entity shall
comply with Section III.B of the Allergan Settlement regarding Cessation of Litigation
Activities.
3. The Governmental Entity shall, within fourteen (14) days of the Reference Date and prior to
the filing of the Consent Judgment, file a request to dismiss with prejudice any Released
Claims that it has filed. With respect to any Released Claims pending in In re National
Prescription Opiate Litigation, MDL No. 2804, the Governmental Entity authorizes the MDL
Plaintiffs' Executive Committee to execute and file on behalf of the Governmental Entity a
Stipulation of Dismissal With Prejudice substantially in the form found at
htt�, _ ���ic�nalo�io��_ W�t..com.
4. T'he Governmental Entity agrees to the terms of the Allergan Settlement pertaining to
Subdivisions and Special Districts as defined therein.
5. By agreeing to the terms of the Allergan Settlement and becoming a Releasor, the
Governmental Entity is entitled to the benefits provided therein, including, if applicable,
monetary payments beginning after the Effective Date.
6. The Governmental Entity agrees to use any monies it receives through the Allergan Settlement
solely for the purposes provided therein.
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7. The Governmental Entity submits to the jurisdiction of the court in the Governmental Entity's
state where the Consent Judgment is filed for purposes limited to that court's role as provided
in, and for resolving disputes to the extent provided in,the Allergan Settlement.
8. The Governmental Entity has the right to enforce the Allergan Settlement as provided therein.
9. The Governmental Entity, as a Participating Subdivision or Participating Special District,
hereby becomes a Releasor for all purposes in the Allergan Settlement, including, but not
limited to, all provisions of Section V (Release), and along with all deparhnents, agencies,
divisions, boards, commissions, Subdivisions, districts, instrumentalities of any kind and
attorneys, and any person in their official capacity whether elected or appointed to serve any of
the foregoing and any agency, person, or other entity claiming by or through any of the
foregoing, and any other entity identified in the definition of Releasor, provides for a release to
the fullest extent of its authority. As a Releasor, the Governmental Entity hereby absolutely,
unconditionally, and irrevocably covenants not to bring, file, or claim, or to cause, assist in
bringing, or permit to be brought, filed, or claimed, or to otherwise seek to establish liability
for any Released Claims against any Released Entity in any forum whatsoever. The releases
provided for in the Allergan Settlement are intended to be broad and shall be interpreted so as
to give the Released Entities the broadest possible bar against any liability relating in any way
to Released Claims and extend to the full extent of the power of the Governmental Entity to
release claims. The Allergan Settlement shall be a complete bar to any Released Claim.
10. The Governmental Entity hereby takes on all rights and obligations of a Participating
Subdivision or Participating Special District as set forth in the Allergan Settlement.
11. In connecrion with the releases provided for in the Allergan Settlement, each Governmental
Entity expressly waives, releases, and forever discharges any and all provisions, rights, and
benefits conferred by any law of any state or territory of the United States or other jurisdiction,
or principle of common law, which is similar, comparable, or equivalent to § 1542 of the
California Civil Code,which reads:
General Release; extent. A general release does not extend to claims that the
creditor or releasing pariy does not know or suspect to exist in his or her favor
at the time of executing the release that, if known by him or her, would have
materially affected his or her settlement with the debtor or released party.
A Releasor may hereafter discover facts other than or different from those which it knows,
believes, or assumes to be true with respect to the Released Claims, but each Governmental
Entity hereby expressly waives and fully, finally, and forever settles, releases and discharges,
upon the Effective Date, any and all Released Claims that may exist as of such date but which
Releasors do not know or suspect to exist, whether through ignorance, oversight, error,
negligence or through no fault whatsoever, and which, if lrnown, would materially affect the
Governmental Entities' decision to participate in the Allergan Settlement.
12.Nothing herein is intended to modify in any way the terms of the Allergan Settlement, to
which the Governmental Entity hereby agrees. To the extent this Settlement Participation
Form is interpreted differently from the Allergan Settlement in any respect, the Allergan
Settlement controls.
2 � ��
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I have all necessary power and authorization to execute this Settlement Participation Form on behalf
of the Governmental Entity.
Signature:
Name:
Title:
Date:
3 0 �
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„EX ���
Subdivision Particia tion and Release Form
Governmental Entity: State:
Authorized Signatory:
Address 1:
Address 2:
City, State,Zip:
Phone:
Email:
The governmental entity identified above ("Governmental Entity"), in order to obtain and in
consideration for the benefits provided to the Governmental Entity pursuant to the Settlement
Agreement dated December 9,2022("CYS Settlement"), and acting through the undersigned authorized
official, hereby elects to participate in the CVS Settlement, release all Released Claims against all
Released Entities,and agrees as follows.
1. The Governmental Entity is aware of and has reviewed the CVS Settlement,understands that all
terms in this Participation and Release Form have the meanings defined therein, and agrees that
by executing this Participation and Release Form, the Governmental Entity elects to participate
in the CVS Settlement and become a Participating Subdivision as provided therein.
2. The Governmental Entity shall promptly, and in any event no later than 14 days after the
Reference Date and prior to the filing of the Consent Judgment, dismiss with prejudice any
Released Claims that it has filed. With respect to any Released Claims pending in In re
National Prescription Opiate Litigation, MDL No. 2804, the Governmental Entity authorizes
the Plaintiffs' Executive Committee to execute and file on behalf of the Governmental Entity a
Stipularion of Dismissal with Prejudice substantially in the form found at
3. The Governmental Entity agrees to the terms of the CVS Settlement pertaining to Participating
Subdivisions as defined therein.
4. By agreeing to the terms of the CVS Settlement and becoming a Releasor, the Governmental
Entity is entitled to the benefits provided therein, including, if applicable, monetary payments
beginning after the Effective Date.
5. The Governmental Entity agrees to use any monies it receives through the CVS Settlement
solely for the purposes provided therein.
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6. The Governmental Entity submits to the jurisdiction of the court in the Governmental Entity's
state where the Consent Judgment is filed for purposes limited to that court's role as provided in,
and for resolving disputes to the extent provided in, the CVS Settlement. The Governmental
Entity likewise agrees to arbitrate before the National Arbitration Panel as provided in, and for
resolving disputes to the extent otherwise provided in,the CVS Settlement.
7. The Governmental Entity has the right to enforce the CVS Settlement as provided therein.
8. The Governmental Entity, as a Participating Subdivision, hereby becomes a Releasor for all
purposes in the CVS Settlement, including without limitation all provisions of Section XI
(Release), and along with all departments, agencies, divisions, boards, commissions, districts,
instrumentalities of any kind and attorneys, and any person in their official capacity elected or
appointed to serve any of the foregoing and any agency, person, or other entity claiming by or
through any of the foregoing, and any other entity identified in the definition of Releasor,
provides for a release to the fullest extent of its authority. As a Releasor, the Governmental
- Entity hereby absolutely, unconditionally, and irrevocably covenants not to bring, file, or
claim, or to cause, assist or permit to be brought, filed, or claimed, or to otherwise seek to
establish liability for any Released Claims against any Released Entity in any forum
whatsoever. The releases provided for in the CVS Settlement are intended by the Parties to be
broad and shall be interpreted so as to give the Released Entities the broadest possible bar
against any liability relating in any way to Released Claims and extend to the full extent of the
power of the Governmental Entity to release claims. The CVS Settlement shall be a complete
bar to any Released Claim.
9. The Governmental Entity hereby takes on all rights and obligations of a Participating
Subdivision as set forth in the CVS Settlement.
10. In connection with the releases provided for in the CVS Settlement, each Governmental Entity
expressly waives, releases, and forever discharges any and all provisions, rights, and benefits
conferred by any law of any state or territory of the United States or other jurisdiction, or
principle of common law, which is similar, comparable, or equivalent to § 1542 of the
California Civil Code,which reads:
General Release; eztent. A general release does not extend to claims that
the creditor or releasing party does not know or suspect to exist in his or her
favor at the time of executing the release that, if known by him or her would
have materially affected his or her settlement with the debtor or released
P�3'•
A Releasor may hereafter discover facts other than or different from those which it knows,
believes, or assumes to be true with respect to the Released Claims,but each Governmental Entity
hereby expressly waives and fully, finally, and forever settles, releases and discharges, upon the
Effective Date, any and all Released Claims that may exist as of such date but which Releasors do
not know or suspect to exist,whether through ignorance,oversight,error,negligence or through no
fault whatsoever, and which, if lrnown, would materially affect the Governmental Entities'
decision to participate in the CVS Settlement.
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11.Nothing herein is intended to modify in any way the terms of the CVS Settlement, to which
Governmental Entity hereby agrees. To the extent this Participation and Release Form is
interpreted differently from the CVS Settlement in any respect,the CVS Settlement controls.
I have all necessary power and authorization to execute this Participation and Release Form on
behalf of the Governmental Entity.
Signature:
Name:
Title:
Date:
3 � �
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Eghi it K
Subdivision and S ecial Di trict ttl ment Partici ation Form
Governmental Entity: State:
Authorized Signatory:
Address 1:
Address 2:
City, State,Zi :
Phone:
Email:
The governmental entity identified above ("Governmental Entity"), in order to obtain and in
consideration for the benefits provided to the Governmental Entity pursuant to the Agreement
dated November 22, 2022 ("Teva Settlement"), and acting through the undersigned authorized
official, hereby elects to participate in the Teva Settlement, release all Released Claims against all
Released Entities, and agrees as follows.
1. The Governmental Entity is aware of and has reviewed the Teva Settlement, understands that
all terms in this Election and Release have the meanings defined therein, and agrees that by
this Election, the Governmental Entiiy elects to participate in the Teva Settlement as provided
therein.
2. Following the execution of this Settlement Participation Form, the Governmental Entity shall
comply with Section III.B of the Teva Settlement regarding Cessation of Litigation Activities.
3. The Governmental Entity shall,within 14 days of the Reference Date and prior to the filing of
the Consent Judgment, file a request to dismiss with prejudice any Released Claims that it has
filed. With respect to any Released Claims pending in In re National Prescription Opiate
Litigation, MDL No. 2804, the Governmental Entity authorizes the Plaintiffs' Executive
Committee to execute and file on behalf of the Governmental Entity a Stipulation of Dismissal
With Prejudice substantially in the form found at .
4. The Governmental Entity agrees to the terms of the Teva Settlement pertaining to
Subdivisions as defined therein.
5. By agreeing to the terms of the Teva Settlement and becoming a Releasor,the Governmental
Entity is entitled to the benefits provided therein, including, if applicable, monetary payments
beginning after the Effective Date.
6. The Governmental Entity agrees to use any monies it receives through the Teva Settlement
solely for the purposes provided therein.
7. The Governmental Enrity submits to the jurisdiction of the court in the Governmental Entity's
state where the Consent Judgment is filed for purposes limited to that court's role as provided
in,and for resolving disputes to the extent provided in,the Teva Settlement.
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8. The Governmental Entity has the right to enforce the Teva Settlement as provided therein.
9. The Governmental Entity, as a Participating Subdivision or Participating Special District,
hereby becomes a Releasor for all purposes in the Teva Settlement, including but not limited
to all provisions of Section V {Release}, and along with all departments, agencies, divisions,
boards, commissions, districts, instrumentalities of any kind and attorneys, and any person in
their official capacity elected or appointed to serve any of the foregoing and any agency,
person, or other entiry claiming by or through any of the foregoing, and any other entity
identified in the definition of Releasor, provides for a release to the fullest extent of its
authority. As a Releasor, the Governmental Entity hereby absolutely, unconditionally, and
irrevocably covenants not to bring, file, or claim, or to cause, assist or permit to be brought,
filed, or claimed, or to otherwise seek to establish liability for any Released Claims against
any Released Entity in any forum whatsoever. The releases provided for in the Teva
5ettlement are intended by Released Entitles and the Governmental Entity to be broad and
shall be interpreted so as to give the Released Entities the broadest possible bar against any
liability relating in any way to Released Claims and extend to the full extent of the power of
the Governmental Entity to release claims. The Teva Settlement shall be a complete bar to
any Released Claim.
10. The Governmental Entity hereby takes on all rights and obligations of a Participating
Subdivision or Participating Special District as set forth in the Teva Settlement.
11. In connection with the releases provided for in the Teva Settlement, each Governmental Entity
expressly waives, releases, and forever discharges any and all provisions, rights, and benefits
conferred by any law of any state or territory of the United States or other jurisdiction, or
principle of common law, which is similar, comparable, or equivalent to § 1542 of the
California Civil Code,which reads:
General Release; extent. A general release does not extend to claims
that the creditor or releasing party does not know or suspect to exist in
his or her favor at the time of executing the release that, if known by
him or her, would have materially affected his or her settlement with
the debtor or released party.
A Releasor may hereafter discover facts other than or different from those which it knows,
believes, or assumes to be true with respect to the Released Claims, but each Governmental
Entity hereby expressly waives and fully, finally, and forever settles, releases and discharges,
upon the Effective Date, any and all Released Claims that may exist as of such date but which
Releasors do not know or suspect to exist, whether through ignorance, oversight, error,
negligence or through no fault whatsoever, and which, if known, would materially affect the
Governmental Entities' decision to participate in the Teva Settlement.
12. Nothing herein is intended to modify in any way the terms of the Teva Settlement, to which
Governmental Entity hereby agrees. To the extent this Election and Release is interpreted
differently from the Teva Settlement in any respect,the Teva Settlement controls.
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I have all necessary power and authorization to execute this Election and Release on behalf of the
Governmental Entity.
Signature:
Name:
Title:
Date:
3 0 �
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EXHIBIT K
Subdivision Participation and Release Form
Governmental Entity: State:
Authorized Si atory:
Address 1:
Address 2:
Ci , State,Zi :
Phone:
Email:
The governmental entity identified above ("Governmental Entity"), in order to obtain and in
consideration for the benefits provided to the Governmental Entity pursuant to the Settlement
Agreement dated December 9, 2022 {"Walgreens Settlement"), and acting through the undersigned
authorized official, hereby elects to participate in the Walgreens Settlement, release all Released
Claims against all Released Entities, and agrees as follows.
1. T'he Govemmental Entity is aware of and has reviewed the Walgreens Settlement, understands
that all terms in this Participation and Release Form have the meanings defined therein, and
agrees that by executing this Participation and Release Form,the Governmental Entity elects to
participate in the Walgreens Settlement and become a Participating Subdivision as provided
therein.
2. The Governmental Entity shall promptly, and in any event no later than 14 days after the
Reference Date and prior to the filing of the Consent Judgment, dismiss with prejudice any
Released Claims that it has filed. With respect to any Released Claims pending in In re
National Prescription Opiate Litigation, MDL No. 2804, the Governmental Entity authorizes
the Plaintiffs' Executive Committee to execute and file on behalf of the Governmental Entity a
Stipulation of Dismissal with Prejudice substantially in the form found at
�nati�nalc��iaidsctticn�ent.com.
3. The Governmental Entity agrees to the terms of the Walgreens Settlement pertaining to
Participating Subdivisions as defined therein.
4. By agreeing to the terms of the Walgreens 5ettlement and becoming a Releasor, the
Governmental Entity is entitled to the benefits provided therein, including, if applicable,
monetary payxnents beginning after the Effective Date.
5. The Governmental Entity agrees to use any monies it receives through the Walgreens
Settlement solely for the purposes provided therein.
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6. The Governmental Entity submits to the jurisdiction of the court in the Governmental Entity's
state where the Consent Judgment is filed for purposes limited to that court's role as provided in,
and for resolving disputes to the extent provided in, the Walgreens Settlement. The
Governmental Entity likewise agrees to arbitrate before the National Arbitration Panel as
provided in, and for resolving disputes to the extent otherwise provided in, the Walgreens
Settlement.
7. The Governmental Enrity has the right to enforce the Walgreens Settlement as provided therein.
8. The Governmental Entity, as a Participating Subdivision, hereby becomes a Releasor for all
purposes in the Walgreens Settlement, including without limitation all provisions of Section XI
(Release), and along with all departments, agencies, divisions, boards, commissions, districts,
instrumentalities of any kind and attorneys, and any person in their official capacity elected or
appointed to serve any of the foregoing and any agency, person, or other enrity claiming by or
through any of the foregoing, and any other entity identified in the definition of Releasor,
provides for a release to the fullest extent of its authority. As a Releasor, the Governmental
Entity hereby absolutely, unconditionally, and irrevocably covenants not to bring, file, or
claim, or to cause, assist or permit to be brought, filed, or claimed, or to otherwise seek to
establish liability for any Released Claims against any Released Entity in any forum
whatsoever. The releases provided for in the Walgreens Settlement are intended by the Parties
to be broad and shall be interpreted so as to give the Released Entities the broadest possible bar
against any liability relating in any way to Released Claims and extend to the full extent of the
power of the Governmental Entity to release claims. The Walgreens Settlement shall be a
complete bar to any Released Claim.
9. The Governmental Entity hereby takes on all rights and obligations of a Participating
Subdivision as set forth in the Walgreens Settlement.
10. In connection with the releases provided for in the Walgreens Settlement, each Governmental
Entity expressly waives, releases, and forever discharges any and all provisions, rights, and
benefits conferred by any law of any state or territory of the United States or other jurisdiction,
or principle of common law, which is similar, comparable, or equivalent to § 1542 of the
California Civil Code,which reads:
General Release; extent. A general release does not extend to claims that the
creditor or releasing party does not know or suspect to exist in his or her favor
at the time of executing the release that, if known by him or her would have
materially affected his or her settlement with the debtor or released party.
A Releasor may hereafter discover facts other than or different from those which it knows,
believes, or assumes to be true with respect to the Released Claims, but each Governmental
Entity hereby expressly waives and fully, finally, and forever settles, releases and discharges,
upon the Effective Date, any and all Released Claims that may exist as of such date but which
Releasors do not know or suspect to exist, whether through ignorance, oversight, error,
negligence or through no fault whatsoever, and which, if known, would materially affect the
Governmental Entities' decision to participate in the Walgreens Settlement.
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11. Nothing herein is intended to modify in any way the terms of the Walgreens Settlement, to
which Governmental Entity hereby agrees. To the extent this Participation and Release Form
is interpreted differently from the Walgreens Settlement in any respect, the Walgreens
Settlement controls.
I have all necessary power and authorization to execute this Participation and Release Form on
behalf of the Governmental Entity.
Signature:
Name:
Title:
Date:
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EXHIBIT K
Subdivision Partici�ation Form
Governmental Entity: State:
Authorized Official:
Address 1:
Address 2:
Ci , State,Zip:
Phone:
Email:
The governmental entity identified above("Governmental Entity"),in order to obtain and in
consideration for the benefits provided to the Governmental Entity pursuant to the Settlement
Agreement dated November 14,2022("Walmart Settlement"), and acting through the undersigned
authorized official,hereby elects to participate in the Walmart Settlement,release all Released Claims
against all Released Entities, and agrees as follows.
1. The Governmental Entity is aware of and has reviewed the Walmart Settlement,understands
that all terms in this Election and Release have the meanings defined therein,and agrees that
by this Election,the Governmental Entity elects to participate in the Walmart Settlement and
become a Participating Subdivision as provided therein.
2. The Governmental Entity shall promptly,and in any event within 14 days of the Effective
Date and prior to the filing of the Consent Judgment,dismiss with prejudice any Released
Claims that it has filed. With respect to any Released Claims pending in In re National
Prescription Opiate Litigation,MDL No. 2804,the Governmental Entity authorizes the
Plaintiffs' Executive Committee to execute and file on behalf of the Governmental Entity a
Stipulation of Dismissal With Prejudice substantially in the form found at
htt�s://nationalo�ioidsettlement.com/.
3. The Governmental Entity agrees to the terms of the Walmart Settlement pertaining to
Subdivisions as defined therein.
4. By agreeing to the terms of the Walmart Settlement and becoming a Releasor,the
Governmental Entity is entitled to the benefits provided therein, including,if applicable,
monetary payments bea nning after the Effective Date.
5. The Governmental Entity agrees to use any monies it receives through the Walmart
5ettlement solely for the purposes provided therein.
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6. The Governmental Entity submits to the jurisdiction of the court in the Governmental
Entity's state where the Consent Judgment is filed for purposes limited to that court's role
as provided in, and for resolving disputes to the extent provided in,the Walmart
Settlement.
7. The Governmental Entity has the right to enforce the Walmart Settlement as provided
therein.
8. The Governmental Entity, as a Participating Subdivision,hereby becomes a Releasor for all
purposes in the Walmart Settlement,including but not limited to all provisions of Section X
(Release), and along with all departments, agencies,divisions,boards, commissions,districts,
instrumentalities of any kind and attorneys, and any person in their official capacity elected
or appointed to serve any of the foregoing and any agency,person, or other entity claiming
by or through any of the foregoing, and any other entity identified in the definition of
Releasor,provides for a release to the fullest extent of its authority.As a Releasor,the
Governmental Entity hereby absolutely,unconditionally, and irrevocably covenants not to
bring,file, or claim,or to cause,assist or permit to be brought,filed, or claimed, or to
otherwise seek to establish liability for any Released Claims against any Released Entity in
any forum whatsoever. The releases provided for in the Walmart Settlement are intended by
the Parties to be broad and shall be interpreted so as to give the Released Entities the broadest
possible bar against any liability relating in any way to Released Claims and extend to the
full extent of the power of the Governmental Entity to release claims. The Walmart
Settlement shall be a complete bar to any Released Claim.
9. In connection with the releases provided for in the Walmart Settlement,each
Governmental Entity expressly waives,releases, and forever discharges any and all
provisions,rights, and benefits conferred by any law of any state or territory of the
United States or other jurisdiction, or principle of common law,which is similar,
comparable,or equivalent to § 1542 of the California Civil Code,which reads:
General Release; extent. A general release does not extend to claims that the
creditor or releasing party does not know or suspect to exist in his or her favor at the
time of executing the release that, if known by him or her,would have materially
affected his or her settlement with the debtor or released party.
A Releasor may hereafter discover facts other than or different from those which it knows,
believes, or assumes to be true with respect to the Released Claims,but each Governmental
Entity hereby expressly waives and fully, finally, and forever settles,releases and discharges,
upon the Effective Date,any and all Released Claims that may exist as of such date but which
Releasors do not know or suspect to exist,whether through ignorance,oversight, error,
negligence or through no fault whatsoever, and which, if known,would materially affect the
Governmental Entities' decision to participate in the Walmart Settlement.
10. Nothing herein is intended to modify in any way the terms of the Walmart Settlement,to
which Governmental Entity hereby agrees. To the extent this Election and Release is
interpreted differently from the Walmart Settlement in any respect,the Walmart Settlement
controls.
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I have all necessary power and authorization to execute this Election and Release on behalf of the
Governmental Entity.
Signature:
Name:
Title:
Date:
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